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Steps to a Full-Lifecycle Drug Diversion
Monitoring Program
Session 228, February 14, 2019
Commander John J. Burke, President, Pharmaceutical Diversion Education
Kara Earle, Drug Diversion Specialist, FairWarning
Moderator: Tyler Carlson, Director of Solution Consulting, FairWarning
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• Define drug diversion and discuss who is diverting what drugs in
care facilities
• Provide an overview of the current drug diversion landscape
• Determine the effects drug diversion has on care providers,
patients, and drug diverters
• Gain a comprehensive overview of a full-lifecycle drug diversion
monitoring program
• Determine the specific steps for implementing a drug diversion
monitoring program
Agenda
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• Defining the current drug diversion landscape
• Outlining the opioid epidemic and addiction
• Sharing drug diversion scenarios and enforcement
• Identifying the effects of drug diversion on the patient, care
provider, and drug diverter
• Creating a 9 step full-lifecycle drug diversion monitoring program
Learning Objectives
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Drug diversion can be defined as “any
illegal act or deviation that removes a
prescription drug from its intended path
from the manufacturer to the patient.”
Diversion occurs at any point along the
supply chain or clinical workflow
What is Considered Drug Diversion?
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The drugs with the highest potential for drug diversion and abuse
are controlled substances, which are classified as such by the U.S.
Drug Enforcement Administration (DEA) based on their intended
medical use, as well as their potential for dependence and abuse.
What Drugs are Being Diverted Most?
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A reputable study states that 15% of care workers are addicted to
drugs, compared to 8% of the general population, due to proximity
and availability of drugs.
Very few drug diversion cases are in relation to financial gain; the
vast majority of cases are addicts feeding their own addiction
Who is Diverting Drugs and Why?
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The 2018 Drug Diversion Landscape
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Bloodborne pathogens
• Important to consider in ALL diversion incidents
• Test offender
• Testing for Hep C
• Testing for HIV
• Take appropriate action if positive
The 2018 Drug Diversion Landscape
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Creating a Full Lifecycle Drug Diversion Monitoring Program
Obtain executive
support and HR buy-in
Formulation of drug
diversion committee
Train staff on how to
identify addicts and
drug diverters
Create anonymous
reporting capability for staff
Hire/empower drug diversion
specialist/investigator
Proactively monitor
Proper reporting to DEA
and law enforcement
Provide
rehabilitation to
addicts
Incorporate findings back into
training and proactive
monitoring programs
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• Garner board support and executive buy-in
• Demonstrate the effects of drug diversion on your
facility
• Evidence the consequences other organizations
have faced
• HR is the gatekeeper of your facility
Capturing Executive Level
Support/HR Buy-In: The Gate
Keepers of Your Facility
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• If an incident can’t be resolved in 24 hours then it
should go to the drug diversion committee
• Usually led by the Head of Pharmacy
• Develop relationships and consider collaboration with:
Legal, Nursing, HR, Pharmacy, Physician, Security,
Compliance
• The makeup of your drug diversion committee will
depend on your facility
Formulation of Drug Diversion
Committee
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Foster a culture of security and compliance by training
your staff to identify impaired coworkers. Signs of drug
diversion may include:
• Excessive shifts
• Heavy ‘PRN’
• Excessive amounts of time spent near a drug supply
• Declining work performance
• Heavy "wastage" of drugs
• Inappropriate prescriptions
• Patient and staff complaints
• Increasing personal and professional isolation
Training Staff to Identify Addicts
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• Determine who will receive anonymous reports
• Reduce fear of reporting
• Formulate a database to standardize the information
• Reduce errors through data tracking, trending,
analyses, and targeted improvement projects
• Make it clear that any drug diverter can reach out for
help with addiction
Create Anonymous Reporting Ability
for Staff
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• Act as head of your drug diversion committee
• Provide expertise and experience with identification of
activity surrounding controlled substances and
chemicals
• Help maintain compliance with the Federal Controlled
Substances Act (CSA)
• Liaison with outside law enforcement and regulatory
agencies
Hiring and Empowering a Drug
Diversion Specialist/Investigator
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• Adopt tools and technology that can
detect instances of drug diversion
• Employ behavioral analytics and artificial
intelligence
• Monitor EMRs and pharmaceutical
dispensing systems such as Pyxis and
Omnicell
Monitor Using Behavioral Analytics
and Artificial Intelligence
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• Report to DEA (Form 106)
• State Licensure Board and/or Professional Assistance
• Law Enforcement - crimes, issues of
abuse/neglect/reckless endangerment, fraud
• FDA/OCI/FBI (tampering cases)
• OIG
The consequences of a lack of reporting:
• David Kwiatkowski case - 18 hospitals, 7 states, 46
people infected
• Lengthy legal battles after diverters are finally caught
Proper Reporting to DEA and Law
Enforcement
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• Confront addict with evidence and empathy
• Determine the best course of action on a case by
case basis
• Facilitate treatment with HR
Addicts in care settings have a 70% rehabilitation rate
versus the 20% of the general population
Resources and Rehabilitation
Options for Addicts
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A crucial step in your drug diversion monitoring program
is to review, analyze, and document findings from your
investigation back into your drug diversion monitoring
program. Ask yourself:
• What did we do well?
• What could we have done better?
• Did we respond quickly enough?
• What was the most time consuming step in the
process?
• Where can we streamline workflows?
Incorporate Findings Back Into Your
Program and Create a Culture of
Compliance and Security
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